PEOPLE v. ARROYO


279 A.D.2d 386 (2001)

720 N.Y.S.2d 33

THE PEOPLE OF THE STATE OF NEW YORK, Respondent, v. MICHAEL ARROYO, Appellant.

Appellate Division of the Supreme Court of the State of New York, First Department.

Decided January 23, 2001.


During a lengthy colloquy, conducted well into the trial, the court, which was already familiar with defendant and his extensive criminal background, fully apprised defendant of the risks and responsibilities involved in waiving counsel and proceeding pro se (see, People v Smith, 92 N.Y.2d 516).

There was ample evidence establishing the element of "physical injury" (Penal...

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